1973) (holding that "[a]n intention on the part of the third person that such wrongful interference results in a loss of affection or family association" is an element).

10-4125-KES, 2011 WL 4345236, at **5-6 (ruling that there was a material issue of fact as to whether there was a loss of affection between spouses).

The Washington court mostly approved of jury instructions stating that the elements to establish a prima facie cause of action for alienation of a child's affections included: (1) an existing family relationship; (2) a third person's wrongful interference with the relationship; with (3) the intention that the wrongful interference results in a loss of affection or family association; (4) a causal connection between the interference and the loss of affection; and (5) that the interference resulted in damages.

Loss of affections is the counterpart to the consortium element in alienation of affections claims.

Although the formulation of the action can vary from state to state, in general "the essential elements of an action for alienation of affection are the marriage, the loss of affection or consortium, the wrongful and malicious conduct of the defendant, and a causal connection between such loss and such conduct.

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